Tickflow Capital Logo
← Legal hub
Legal · Data & Privacy

Privacy Policy

This Privacy Policy explains how Tickflow Capital Limited collects, uses, stores, and protects personal data, in compliance with Kenya's Data Protection Act 2019 (DPA) and applicable international standards.

Effective Date1 April 2026
Last Updated28 April 2026
ControllerTickflow Capital Limited
Governing LawLaws of Kenya
Contents
  • 1. Who We Are
  • 2. Data We Collect
  • 3. How We Use Your Data
  • 4. Legal Basis
  • 5. Data Sharing
  • 6. Data Retention
  • 7. Security
  • 8. Your Rights
  • 9. International Transfers
  • 10. Children
  • 11. Cookies
  • 12. Changes
  • 13. Contact

1. Who We Are

Tickflow Capital Limited ("Tickflow Capital", "we", "us", or "our") is a trading technology and quantitative research company incorporated in Kenya under the Companies Act 2015.

  • Registered name: Tickflow Capital Limited
  • Registration number: PVT-6Y1YWM6V
  • Registered address: Ruiru, Kiambu, Kenya
  • Contact email: info.tickflowcapital@gmail.com

We operate the website tickflowcapital.com and the TIES (Trading Intelligence & Execution System) platform. In the context of this Privacy Policy, we are the data controller for personal data collected through our website and communications. Where we process data on behalf of commercial clients, we may act as a data processor as defined in the Kenya Data Protection Act 2019.

2. Data We Collect

We collect personal data only to the extent necessary for legitimate business purposes. We do not collect excessive, irrelevant, or speculative data.

2.1 Data You Provide Directly

CategoryExamplesHow Collected
Identity dataFull name, job title, company nameContact form, email enquiries
Contact dataEmail addressContact form, direct email
Communication dataContent of messages, enquiry type, message bodyContact form submissions
Commercial dataProduct interest, firm type, use case descriptionsContact form selection fields

2.2 Data Collected Automatically

CategoryExamplesPurpose
Technical dataIP address, browser type, operating systemSecurity, fraud prevention
Usage dataPages visited, time on site, referral sourceAnalytics (if enabled)
Device dataScreen resolution, device typeSite optimisation

2.3 Data We Do Not Collect

We do not collect:

  • Financial account numbers, bank details, or payment card data (payments, if applicable, are handled by Stripe - see Section 5)
  • Government-issued identification numbers (unless required for KYC/AML compliance in specific commercial arrangements)
  • Biometric data
  • Health or medical data
  • Data from individuals under 18 years of age
  • Social media profile data beyond what you voluntarily share in direct communications
No account system currently: Tickflow Capital Limited does not currently operate user accounts or login portals for its public website. Data collected is limited to that submitted via our contact form and standard server-side technical logs.

3. How We Use Your Data

We use personal data only for specified, explicit, and legitimate purposes. We do not use data for automated profiling or decision-making that produces legal effects.

PurposeData UsedLegal Basis
Responding to enquiries and contact form submissionsIdentity, contact, communication dataLegitimate interest / Contractual necessity
Providing information about our products and servicesIdentity, contact, commercial dataLegitimate interest / Consent
Managing commercial relationships and contractsIdentity, contact, commercial dataContractual necessity
Complying with legal and regulatory obligationsAs required by lawLegal obligation
Improving our website and servicesTechnical, usage data (anonymised)Legitimate interest
Security monitoring and fraud preventionTechnical dataLegitimate interest

We do not use your personal data for unsolicited marketing, selling to third-party advertisers, or any purpose not listed above. We do not sell personal data.

4. Legal Basis for Processing

Under the Kenya Data Protection Act 2019, we process personal data on the following lawful bases:

  • Consent: Where you have given clear, informed consent (e.g., optional communications).
  • Contractual necessity: Where processing is necessary to fulfil a contract with you or to take steps at your request prior to entering a contract.
  • Legal obligation: Where we are required to process data to comply with a legal or regulatory obligation.
  • Legitimate interests: Where processing is necessary for our legitimate business interests (e.g., security, fraud prevention, service improvement), provided those interests are not overridden by your rights and interests. We have assessed each such use and determined it is proportionate and necessary.

Where we rely on consent, you have the right to withdraw that consent at any time by contacting us at info.tickflowcapital@gmail.com. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

5. Data Sharing and Third Parties

We do not sell, rent, or trade your personal data. We share personal data only in the following limited circumstances:

5.1 Service Providers (Data Processors)

We engage the following third-party service providers who may process personal data on our behalf:

ProviderPurposeLocation
Cloudflare Inc.CDN, DDoS protection, DNS, securityUnited States
Web3FormsContact form submission processing and email deliveryUnited States
Stripe Inc. (future Phase 4)Payment processing for commercial subscriptionsUnited States
Oracle Cloud InfrastructureVPS hosting for backend servicesUnited States / Global
GitHub Inc.Source code hosting and site deploymentUnited States

All service providers are contractually bound to process personal data only on our instructions and in accordance with applicable data protection laws.

5.2 Legal Disclosure

We may disclose personal data to:

  • Regulatory authorities or law enforcement agencies where required by law, court order, or legal process.
  • Competent authorities for compliance with anti-money laundering (AML) or counter-terrorism financing (CTF) obligations.
  • Professional advisers (lawyers, accountants, auditors) bound by confidentiality obligations.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred to the acquiring entity. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.

6. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law.

Data CategoryRetention PeriodBasis
Contact form submissions (general enquiries)12 months from date of submissionLegitimate interest in follow-up and business development
Commercial correspondence and contracts7 years from contract end dateKenya Companies Act; tax and legal obligations
Payment records (if applicable)7 yearsKenya Tax Procedures Act 2015
Technical logs (server, security)90 daysSecurity monitoring and incident investigation
Marketing communications dataUntil consent is withdrawn, or 2 years of inactivityConsent

When personal data is no longer required, we securely delete or anonymise it. Anonymised data (which can no longer identify you) may be retained indefinitely for research and analytical purposes.

7. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, or disclosure.

Technical Measures

  • All data in transit encrypted via TLS 1.2 or higher
  • Website served via Cloudflare with DDoS protection and HTTP/3 support
  • Backend services hosted on Oracle Cloud with restricted network access
  • Access controlled via Cloudflare named tunnels - no direct public exposure
  • Redis data encrypted at rest and access-controlled
  • PostgreSQL databases with role-based access control

Organisational Measures

  • Access to personal data limited to personnel with a legitimate need
  • Incident response procedures in place
  • Regular security review of external-facing systems
  • Third-party service providers assessed for security prior to engagement

No transmission of data over the internet is completely secure. While we take all reasonable precautions, we cannot guarantee the absolute security of data transmitted to or from our website.

To report a security vulnerability or data breach, contact us immediately at info.tickflowcapital@gmail.com or via our security disclosure at tickflowcapital.com/.well-known/security.txt.

8. Your Rights Under Kenya's Data Protection Act 2019

As a data subject, you have the following rights under the Kenya Data Protection Act 2019:

RightWhat It Means
Right of accessYou may request confirmation of whether we hold your personal data and obtain a copy of it.
Right to rectificationYou may request correction of inaccurate or incomplete personal data.
Right to erasureYou may request deletion of your personal data where there is no compelling reason for its continued processing.
Right to restrictionYou may request that we restrict the processing of your data in certain circumstances.
Right to data portabilityYou may request a copy of your data in a structured, machine-readable format.
Right to objectYou may object to processing based on legitimate interests or for direct marketing purposes.
Right to withdraw consentWhere we rely on consent, you may withdraw it at any time without affecting prior processing.

To exercise any of these rights, contact us at info.tickflowcapital@gmail.com. We will respond within 30 days. We may require you to verify your identity before processing your request.

If you are unsatisfied with our response, you have the right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC) of Kenya at www.odpc.go.ke.

9. International Data Transfers

Some of our third-party service providers are located outside Kenya (primarily in the United States). When we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

  • Contractual clauses that require the recipient to protect personal data to standards equivalent to those under Kenyan law
  • Use of service providers that operate under recognised data protection frameworks (e.g., EU Standard Contractual Clauses where applicable)
  • Assessment of the legal environment in the recipient country to ensure adequate protection

By submitting data through our website, you acknowledge that your data may be transferred to, stored, and processed in countries outside Kenya, subject to the safeguards described above.

10. Children's Privacy

Our website and services are intended solely for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18 years of age. Our products involve financial technology and trading systems that are not appropriate for minors.

If we discover that we have inadvertently collected personal data from a minor, we will delete that data immediately. If you believe we have collected data from a minor, please contact us at info.tickflowcapital@gmail.com.

11. Cookies and Tracking

Our website uses limited cookies for essential functionality. We do not use advertising cookies, cross-site tracking, or third-party analytics tools that collect personal data without your consent.

For full details on the cookies we use, how we use them, and how to control them, please read our Cookie Policy.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or operational changes. When we make material changes, we will:

  • Update the "Last Updated" date at the top of this page
  • Post the updated policy on our website
  • Where required by law, notify affected individuals directly

We encourage you to review this policy periodically. Your continued use of our website or services after changes are posted constitutes your acceptance of the updated policy.

13. Contact Us

For questions, concerns, or requests relating to this Privacy Policy or your personal data:

  • Email: info.tickflowcapital@gmail.com
  • Entity: Tickflow Capital Limited
  • Address: Ruiru, Kiambu, Kenya

We aim to respond to all privacy-related enquiries within 30 calendar days. For formal complaints, you may also contact the Office of the Data Protection Commissioner of Kenya.

Tickflow Capital Logo
Tickflow Capital Limited · PVT-6Y1YWM6V · Nairobi, Kenya
Legal Hub Cookies Terms Risk
© 2026 Tickflow Capital Limited. All rights reserved. Governed by the laws of Kenya.